Residence may seem to be a relatively simple thing to determine. It’s where you live, right? Well, leave it to the Internal Revenue Code to complicate this question. There are different tests for residency when it comes to...more
The term “resident” is defined differently for US federal income tax purposes and US federal estate and gift tax purposes. The mismatch in the US resident status under the two tax regimes often gives rise to problems. Thus,...more
Takeaways: •The Office of the Attorney General for D.C. announced a $40 million settlement with Michael Saylor and MicroStrategy, Inc., marking the largest income tax recovery in D.C. history. •The resolution arose from a...more
Clients frequently come to us while in the process of selling interests in California-based businesses. Clients who are not residents of California typically expect that they will not be subject to California income tax on...more
On July 21, 2023, New Jersey Governor Phil Murphy signed Assembly Bill No. S3128/A4694 into law, which implements an aggressive tax treatment of nonresidents who work for New Jersey employers. The law essentially adopts the...more
Muchos ciudadanos americanos que viven en el extranjero no presentan su declaración de impuestos en Estados Unidos de América (“EUA”) por diversas cuestiones. Generalmente, esto sucede porque se tiene la creencia que no es...more
Under California Governor Gavin Newsom's proposed 2023-2024 state budget, released on January 10, 2023, the income of an incomplete gift non-grantor trust (ING Trust) may now be subject to California income tax, effective on...more
There seems to be an increased number of so-called “residency audits” being conducted by the Alabama Department of Revenue (ALDOR), as well as by other state tax authorities. These audits often result from the taxpayer filing...more
For Americans and other foreign residents, Mexico is a very attractive country to live and work, because of its weather, rich culture, delicious food, friendly locals, and cost of living. And in an increasingly global...more
Is the grass always greener on the other side? Like any major life decision, deciding to uproot yourself (and potentially your family) and move from one state to another is not an easy decision. Although laws, taxes and...more
U.S. Tax Residency Status - As a general matter, all U.S. citizens and U.S. residents are treated as U.S. tax residents. A non-U.S. citizen is generally classified as a nonresident for U.S. tax purposes unless they satisfy...more
On June 30, 2022, the New York State Supreme Court ruled in Matter of Nelson Obus that the ownership of a seldom used New York State vacation home did not cause its New Jersey domiciled owners to be treated as statutory...more
State personal income tax issues related to residency and domicile, because of their fact-dependent nature, are often the subject of controversy and litigation. Taxpayers have a fresh win in this area to celebrate. The New...more
Escape from New York- According to data released by the IRS earlier this year, the pandemic triggered a “wealth migration” that saw high-tax states like New York lose high-income earners to low-tax jurisdictions such as...more
In a previous post, we provided an overview for determining a person's U.S. income tax residency status under the substantial presence test (the "SPT"), a test which relies on a mathematical formula for computing an...more
1. Types of Business Entities - The main business entities in Greece are the following: i) the Société Anonyme (S.A.); ii) the Private Company (P.C.); iii) the Limited Liability Company (Ltd); iv) the General Partnership...more
What does it mean to be a U.S. income taxpayer? Very simply, it means that you are taxable on your worldwide income and gains, even if you don't live full-time in the U.S. Any U.S. citizen is likely already familiar with this...more
In a recent Board of Tax Appeals Case, taxpayers contested the Department’s assessment of personal income taxes, asserting that they were not Ohio residents. See Anthony R. Joy & Robin E. Miller, (et. Al.), v. Jeffrey A....more
Employees working remotely outside the UK during Covid-19 may create – and may already have created – expensive tax liabilities for themselves and their employers....more
Many people are looking to move out of high tax jurisdictions - for a variety of tax and non-tax reasons. State tax officials audit residency changes with vigor. Betsy Smith joins Matt Hunsaker in the virtual studio to...more
If you are a US citizen who is becoming UK resident you will continue to be subject to US tax and reporting obligations but will also become subject to UK tax. Although there is a double tax treaty between the US and the UK...more
KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER GREEK LAW - 1. PROCEDURE – MAIN STEPS OF REAL ESTATE ACQUISITION UNDER GREEK LAW. Acquisition of real estate property in Greece includes mainly the following steps: •...more
The guidelines for determining an Individual’s tax residency are as follows: - An Individual Taxpayer is a resident based on the laws of one treaty-partner country and is considered to be a resident of that country for...more
The payment and withholding of earned income taxes (“EIT taxes”) in Pennsylvania at times seems like a complex maze and is challenging for human resource professionals or a company’s payroll tax team. In May, Pennsylvania...more